On Point blog, page 1 of 61
COA upholds default order despite some “questionable” aspects of case, finds court properly exercised discretion at dispo
State v. S.B.T., 2026AP1890, 11/4/26, District II (ineligible for publication); case activity
Although S.B.T. presents a number of mitigating facts to excuse her nonappearance, COA holds the circuit court did not erroneously exercise its discretion and rejects her challenges to the disposition.
COA affirms TPR default judgment entered after one missed hearing
State v. M.R., 2026AP1742 & 2026AP1743, 10/20/26, District I (ineligible for publication); case activity
COA holds that the circuit court properly exercised its discretion when it found “Margo” in default when she missed one court appearance and affirms orders terminating her parental rights.
COA rejects multiple challenges to TPR and affirms
Rock County Human Services Department v. T.S., 2026AP1628-29, 10/15/26, District IV (ineligible for publication); case activity
Although T.S. presents a medley of interesting legal challenges, COA beats backs those arguments and affirms.
COA finds that “impossibility” is not a defense to failure to assume a parental relationship; affirms TPR
State v. K.T.R., 2026AP929, 10/14/26, District II (ineligible for publication); case activity
COA holds that the jury’s “impossibility” finding with respect to the continuing CHIPS allegation does not “carry over” to the failure to assume ground and affirms an order terminating parental rights.
COA rejects multiple challenges to appointment of guardian for child
Monroe County v. T.L.B., 2025AP2519, 9/24/26, District IV (ineligible for publication); case activity
T.L.B. appeals an order appointing a guardian of the person for her minor child, G.L.W., under WIS. STAT. § 48.977. She makes numerous arguments, including that the circuit court applied the incorrect legal standard and that its conclusions were erroneous. COA affirms.
Appellant forfeited right to challenge circuit court exercising concurrent jurisdiction with tribal court over guardianship proceeding because objection to jurisdiction not raised in circuit court.
Monroe County v. G.L.B., 2025AP2239, 9/24/26, District IV (ineligible for publication); case activity
The COA held that the appellant forfeited his right to appeal the circuit court exercising concurrent jurisdiction with the Ho-Chunk Nation tribal court on Monroe County’s guardianship petition because he did not raise his arguments in the circuit court.
COA affirms TPR order over erroneous exercise challenge
State v. E.L., 2026AP1497, 9/9/26, District I (ineligible for publication); case activity
“Emily” appeals the circuit court’s order terminating her parental rights to her child, “Gretchen,” arguing that the court erroneously exercise of discretion when it found that termination was in Gretchen’s best interests. Emily claims the court failed to consider whether Gretchen had substantial relationships with other family members, and whether it would be harmful to her if those relationships were severed. COA affirms.
COA holds that termination of parental rights automatically terminates the parent’s obligation to pay child support, and the parent is entitled to be reimbursed for overpayments.
Rhiannon M. Stroede v. Jason R. Royal, 2025AP2654, 9/3/26, District IV (not recommended for publication); case activity
The COA held that an order terminating a parent’s rights to a child automatically terminates the parent’s obligation to pay child support and the parent is entitled to be reimbursed for any overpayments.
COA rejects challenge to exercise of discretion at TPR disposition hearing
State v. Y.M., 2026AP1212, 8/27/26, District I (ineligible for publication); case activity
“Yolanda” challenges the circuit court’s exercise of discretion at disposition, arguing that the evidence lacked “complete and meaningful testimony” from the children’s foster placements and potential adoptive parents. COA rejects these arguments and affirms.
COA: Circuit court does not lose competency in TPR proceeding when it fails to comply with statutory requirement to hear testimony to support grounds for termination before accepting plea.
Barron County v. K.L.P., 2026AP460 & 2026AP461, 7/21/26, District III (ineligible for publication); case activity
The COA held that the circuit court did not lose competency to enter disposition orders in an action to terminate parental rights if it accepts a no-contest plea to the grounds for termination without hearing testimony, even if Wis. Stat. § 48.422(3) requires testimony.